BOARD Fran Offenhauser, President John Clifford, Vice President Libby Simon, Recording Secretary Kay Tornborg, Treasurer Robert S. Birchard Tyler Cassidy Phil Dockter Aaron Epstein Marian Gibbons Dave Greim Julian “Bud” Lester Steven R. Osborn Marvin Paige Bill Roschen Jeffrey Rouze Richard Rownack Andrew Schwartz Arnold Scwhartzman Natalie W. Shivers Marc Wanamaker DIRECTOR FOR Robert W. Nudelman Kay Tornborg EXECUTIVE DIRECTOR, Stephen X. Sylvester DIRECTOR, THE SILENT SOCIETY Randy Haberkamp DIRECTOR OF MEMBERSHIP DEVELOPMENT Mary Sullivan Claire Bradford Baldwin, Ray Bradbury, Author Sally Beaudette, Consultant Ray Courts, Hollywood Collectors Show,
Inc. Art Laboe, Radio Personality, Betty Lasky, Author Milt Larsen, Founder, Magic Castle Ronald Neame, Director, Producer, Writer Ceilia DeMiille Presley, Anthony Slide, Historian Barbara Zicka Smith, Ann Savage, Actress Delmar Watson, Photo Archivist Michael York, Actor Pat York, Photographer, author
PRESERVATION ISSUESIMMEDIATE PAST PRESIDENT
WATTLES MANSION &
GARDENSADVISORY BOARD
Hollywood Holding Co.
CEO Original Sound
Philanthropist
Executive Director, American Cinematheque
Response to Revised CEQA Negative Declaration for Fire Station No. 82—Hollywood (W.O. E170064B)
Mr. Carter Adkins
City of Los Angeles
Department of Public Works
Bureau of Engineering April 26, 2005
650 S. Spring St.
Suite 574
Los Angeles, CA 90014Hollywood Heritage supports the location of the proposed new fire station at the described grouping of the lots. What we do not support is the need for demolition of the 1938 Florentine Gardens building. First, because there is no need for its demolition to accommodate the proposed station, and secondly because the Negative Declaration (Neg Dec) fails to justify the demolition. It also must be noted that while the Neg Dec makes considerable mention of the problems of the project meeting the conditions of the Hollywood Community Plan (HCP), it makes no mention of the conditions of the 1986 Hollywood Redevelopment Project Plan (and amendments) which supercede the HCP and is therefore the legal plan at issue here. As will be shown, the Neg Dec does not comply with conditions of the Redevelopment Plan and is therefore without legal merit and cannot be certified.
Hollywood Heritage is concerned with the Florentine Gardens building and not the former grocery store/theater, etc. structure located to the immediate west (5959 Hollywood Boulevard). Demolition there is not a problem. This response refers, in specific, to “Issue 5 Cultural Resources” of the Neg Dec and the project’s negative impact on cultural resources as governed by CEQA.
The proposed project consists of a 16,000 sq. ft. fire station, a 6,000 sq. ft. apparatus storage building, and a 2,500 sq. ft. multi-purpose room. The station would be two stories tall (see page 3 “C Description”–all references herein refer to the Neg Dec unless otherwise noted). The site is 3.04 acres, though no description of the required amount of land needed for the fire station is given, a significant piece of information needed to properly evaluate this Neg Dec. At previous meetings and in discussions that Robert W. Nudelman had in February and March 2005 at the Myra Franks and Associates offices and on site with, among others, Carter Atkins, the Neg Dec’s preparer, the required land amounted to between one and one and one half acres.
The one-acre site had already been approved for a previous location (Grammercy Avenue and Hollywood Boulevard) for this station.
Based on the maximum requirement there is a surplus of at least one and one-half acres or more. Therefore, half the proposed site to be purchased is not necessary for the fire station. The Florentine Gardens main building is 16,000 sq. ft. and additional structures cover approximately 4,500 sq. ft. (“Primary Record Filing,” page 2 section B6). This would amount to less than one-half of an acre in size (an acre being approximately 43,000 sq. ft.), leaving over an acre of land unused by either the fire station or the Florentine Gardens structures. The issue of parking for the Florentine Gardens would have to be looked at when a use is determined (the existing use would be terminated as planned by the city now). Parking could be added to from nearby empty lots, or by building a structure on the unused one plus acre. But it should be remembered that this issue is immaterial to the Neg Dec and should not, therefore, be used as a condition on whether to preserve the Florentine Gardens, although conditions do exist that would make most uses viable when the building is adaptively reused.
Based on this factual information, there is more than adequate land with plenty of frontage to allow for the development of the proposed fire station without demolishing the historic Florentine Gardens structures. There is also additional land on site to use for parking that can be expanded with the building of a parking structure or by utilizing nearby parking lots.
HOLLYWOOD REDEVELOPMENT PLAN (Plan)
The Plan was required to include a “Determination of Eligibility Report” (Report), designating structures of historic importance based solely on exterior appearance (no interiors were evaluated). This Report was prepared and submitted in September 1984 and was included as part of the approval documents for the Hollywood Redevelopment Project on May 7, 1986. The report is thereby a binding section of the Plan.
The Report states that the information concerning historic significance has been reviewed and approved as follows:
“It is understood that these conclusions (the designations—ed. note) will be reviewed by the staff of the SOHP on behalf of the State Historic Preservation Officer.
“It should be emphasized that the selection of buildings and districts included in this inventory and the consultant’s evaluation of their National Register status are based on usual assessments of architectural quality, integrity, and supportive neighborhood context. The consultants relied on existing research to identify buildings whose non-descript or highly altered appearance might mask historic significance. The extensive research necessary to identify other properties which possess historic, but not architectural importance was outside the scope of the current study. Therefore, it may be possible that additional structures, not currently documented, within the project area (sic), could be found to qualify for designation programs based solely on historic significance.” (“Determination of Eligibility Report” pages 4-5.)
In this Report the Florentine Gardens was given a designation of “5.” As the report points out, it did not include any interior reviews, nor did it include an evaluation of any cultural/historic significance when assessing the designation. The cultural/historic importance was to have been prepared by May 7, 1986 in a separate evaluation report of the Redevelopment Project Area, but has yet to be started.
So without any evaluation of the interior or of the cultural/historic significance of the Florentine Gardens having been made, the “5” designation was given, approved by the CRA, the State, and the Los Angeles City Council. In addition, the importance of the report and its designations was stressed as evidence in the 1986 lawsuit of Save Hollywood Our Town (SHOT) vs. the CRA, et. al. so the validity of the designation has also been confirmed in the courts and on appeal.
Thus the Plan has determined, with considerable review, that the Florentine Gardens building is of significance. As no change to the exterior has been made since 1984, and review of the surviving interior elements and the historical/cultural background of the building in the Neg Dec was never made, these would only add to the value of the designation, giving it more significance than a “5.”
As such, the Florentine Garden is protected as if it were a Los Angeles City landmark (pages 42- 44, Section 511 of the Plan). This overrules the Neg Dec as the Plan clearly states on page 16, section 407.1.1 Development Plans: “All development (whether public or private) shall be subject to review and approval by the Agency. All development in the Project Area must conform to the Redevelopment Plan.” (emphasis added.)
The city is thus required to accept the designation unless it demonstrates changes made since 1984 that would compromise that evaluation. No such claims are made in the Neg Dec, nor would they be valid. It should be noted that any de-designation process would require a period of one year. This may trigger other issues in the Plan that would cause further delays beyond that one year.
THE NEGATIVE DECLARATION
The Neg Dec is clearly a case of the author attempting to fulfill the client’s demands and a failure to evaluate the history and cultural significance of the Florentine Gardens. As stated previously, the 1984 “Determination of Eligibility Report” gave the building a rating of “5.” This was reviewed and approved by several state and local governing bodies and agencies and used as evidence in court to defend the Redevelopment Project. At no time did any of these entities ever challenge the rating. Further evidence of the integrity of the interior and the building’s association with famous people only strengthens the rating, not weakens it. The “5” rating was given as if no interior elements remained and without any consideration for events or people of importance being associated with the structure.
What the Neg Dec provides is an interpretation under which the designation ratings go askew. For example, despite trying to degrade the status of the Florentine Gardens, contradictory information is provided on page 2 of the Historical Assessment for 5951-55 and 5959 Hollywood Boulevard (3/28/05). It states that even the revised (though not yet approved by the CRA) version of the 1984 survey still noted the Florentine Gardens at level “5”.
Yet in the Neg Dec’s attack on this status (which was given by Myra Franks and Associates in 2002) it refers to a grade of level “2” for 5941 Hollywood Boulevard, the building to the immediate east of the Florentine Gardens. This building is the Salvation Army Tabernacle today, having been built as the Hawaiian Theater in 1939 (Historical Assessment for 5951-5 and 5959 Hollywood Boulevard, page1). Yet the CRA report gave it a “5” rating in 1984, not the considerably more important “2” rating.
Despite the modifications to the exterior of the Florentine Gardens, elements are still there and it is still recognizable from earlier photos, and the modernizations were made during the period of significance according to the Neg Dec. The Hawaiian Theater though, was a streamline moderne theater with various façade embellishments, none of which are visible today. The interior does contain the space of the lobby and the theater, but all decorative elements have been covered or removed.
If stucco coverings are removed and the theater restored to its original appearance, this site would indeed merit the “2” rating. But in its current state, the “5” rating is appropriate. The Florentine Garden is in far more intact condition at this time than the Hawaiian Theater (hopefully it can be restored some day by removal of the stucco). But the Neg Dec offers no explanation of how a building in a condition of less actual integrity inside and out and with no association with peoples or events of importance, has somehow gone up in historic status, while the Florentine Garden, as described in the Neg Dec, went down, both by significant degrees.
No explanation is given in the Neg Dec to explain why the 1984, and the 2002 revision of the Determination of Eligibility survey are inaccurate in their findings. All the more important is that the 2002 revision and the historic evaluation in the Neg Dec were both prepared by the same firm, Myra Frank and Associates, hence the opinion created here that the client and not CEQA is being served in the Neg Dec.
Hollywood Heritage supports the 1984 and 2002 documents with the strong possibility that when an unbiased review of the additional information on the interior and the association of the structure with people of importance is taken into account, the correct level would be “4.” To lower it makes no sense whatsoever, legally or otherwise, as no evidence is presented in the Neg Dec to challenge either the 1984, nor their own 2002 reports, prepared for a neutral third party, the CRA. It can only be presumed that those reports represent an accurate, unbiased, determination of significance. The Neg Dec, prepared for a party advocating demolition, is therefore biased in nature and does not represent an adequate or legal evaluation under CEQA.
FINDINGS IN THE NEG DEC
Exterior
The Neg Dec points out that the Florentine Gardens exterior remained virtually the same from the 1938 opening until 1953. At that time a new owner, the Hollywood Canteen Foundation (no further information is provided concerning the involvement of the significant new owner), hired famed architect Paul R. Williams to “upgrade” the nightclub’s structure inside and out (Primary Record, page 5, B6). The changes made by Williams are almost identical to the list shown on page 18 of the Primary Record. This indicates that the new 1953 exterior appearance was the result of the vision and design of Williams. Very few, if any, modifications were made to the existing exterior after 1953 (Primary Record, page 25). Permits described on pages 6-7 of the Primary Record are for interior work, with the exception of a new sign for the Retail Clerk’s Union in 1955.
Therefore the current façade, with minor exceptions, is a Paul Williams modified vision of a Gordon B. Kaufman structure. More telling is the original description in the 1953 permit, not detailed in the Neg Dec, that was read by Jessica Feldman of Myra Franks and Associates at the aforementioned Feb. 2005 meeting. Also present at this meeting was Robert Nudelman of Hollywood Heritage, Ken Bernstein of LA Conservancy, Rick Starczak of Myra Franks and Associates, and Carter Atkins. Ms. Feldman read the permit and it was almost identical to the list on page 18 of the Primary Record. That list of permitted work is not included in the Neg Dec so as to compare it to the list on page 18, which is now used to show the lack of façade integrity.
Also dismissed in the Neg Dec is that these modifications took place during the period of significance from 1938-55. Yet somehow the Neg Dec claims that the Florentine Gardens “has lost integrity of design, setting, materials, workmanship, feeling, and associations from its period of significance (1938-55).” (Historical Assessment for 5951-55 and 5959 Hollywood Boulevard, page 5.) This obviously is not true since the Neg Dec makes no claim that the “losses” occurred after 1955, but rather almost exclusively in 1953. Additionally, the Florentine Gardens continued to operate there, as before, until 1955.
The Neg Dec creates an argument that is the basis for the conclusion that the 1953 permits somehow took place in 1955 or later though no evidence to support this is presented. Though Paul R. Williams is the 1953 architect of record, once more the Neg Dec attempts to discredit the facts to bolster its conclusions by dismissing Williams’ involvement. This conclusion is purely speculative. The two references used to deny any significance of Williams on this project are, again, speculative as neither knew of Mr. Williams’ involvement or non-involvement. The legal record is the permit, and it is what must be the determining factor as to who the architect of record is.
But if speculation is desired, it would only increase the validity of Mr. Williams’ involvement. The Florentine Gardens went through an ownership change in 1953. The new owners proceeded to give the building a new design in an attempt to “upgrade” the facility. This was being done by its main competitor, the Earl Carroll Theater (located a few blocks away on Sunset Boulevard). The Earl Carroll also changed hands that year and would reopen in 1953 as Frank Sennes’ Moulin Rouge nightclub. Pages 8-13 of the Primary Record contain a meaningless, as far as comparisons go, list of Hollywood area restaurants. The only comparable on this list, to the Florentine Gardens in both entertainment content and audience size, was the Earl Carroll Theater, which was also designed by Gordon B. Kaufman and opened in 1938. With the change in operations and the changes in taste taking place between 1938 and 1953, the Florentine Gardens and Earl Carroll Theater both required an overhaul to keep up with the times and each other.
The Florentine Gardens brought in Paul R. Williams, a highly respected local architect of national renown, who had been the architect for numerous celebrity homes and businesses (including the similarly styled Perino’s restaurant in 1950). Williams had also done several remodels where he would, as was done by most architects of the time, strip off ornamentation to create a new, clean, modern look for post-WWII rehabilitation projects. Williams’ celebrity relationships and his fame as a modern-style architect made him a natural choice to remodel, and hopefully reinvigorate, the Florentine Gardens.
What remains today is a façade that, with minor exceptions, is Paul R. Williams’ vision. No other name is presented in the Neg Dec as the actual architect, nor was any explanation of who is then the architect if the permits were fraudulent in using his name. Williams’ involvement makes complete sense for the time, use, and clientele. The Neg Dec also makes no claims that the 1953 remodeling has been significantly, or even at all, modified up to today. The work therefore occurred during the period of significance and represents a historical design of that time. The Florentine Gardens is the only structure in Hollywood that is credited to Mr. Williams. It is therefore unique to the Hollywood area.
Interior
The interior modifications to the 1938 structure are principally cosmetic in nature. The main dance floor, or auditorium area, remains with a huge truss ceiling over 20 ft. high. This ceiling is considerably exposed to the roof to allow for light, sound, and ventilation equipment to be installed, then as now. The north end still contains the stage area in a size and shape that appears to match photos from the early 1940s. The ZanziBar area to the east side of the main floor is elevated and contains what appears to be the original bar, stretching almost the length of the room. Areas both beneath and behind the bar also appear original to the period of significance. The lobby space is the same in location, but has had some realignment of doorways, especially to the upstairs (now blocked off). A circa 1940s ticket booth is located just inside the main entryway.
Other areas remain remarkably intact. The men’s washrooms contain tile and fixtures that are almost entirely circa 1940. The dressing rooms are still intact, though some partition walls have probably been removed. The kitchen area is also evident and the stainless steel chute to send cloths or food to the delivery area in back is still present. The VIP entrance on the western side is still there, along with the exterior stairway (modified in 1953). The original lighting/sound control booth is still in use as such at the south end of the main auditorium, with a small post-1979 extension added.
In short it would be next to impossible to not know what was going on inside the building during the period of significance by visiting it today. You walk in past the ticket booth through a lobby and into a spectacular open space (with a capacity of over 1500) and see an obvious stage area at the far end. A control room overlooks the floor area and stage area from above, controlling an elaborate lighting and sound system. A very long stainless steel bar is seen in a room slightly elevated, though open to the main floor, with a full set of mechanical and plumbing equipment. Downstairs are obvious dressing rooms and a kitchen area. Upstairs is a special entrance on the side of the building that connects to the stage area or down to the main floor.
The cosmetic coverings are, for the most part, missing, but the space is perfectly defined throughout. As noted several times in the Neg Dec, nightclubs such as this would go through periodic renovations altering the cosmetic elements of the interior. If every structure nominated for any designation for its interior detailing to be fully intact after 67 years, very few would be nominated and many current landmarks would be removed. Two examples of extensive interior remodeling include the Cocoanut Grove and the Biltmore Bowl, both of which bear almost no resemblance, and certainly no more than the Florentine Gardens, to their original appearance. The Florentine Gardens is actually in far better condition than almost any similar structures from that era, is still being used for its original purpose, and as the aforementioned list of Hollywood area restaurants shows, is one of the very few still standing and being used as such today (only six out of sixty-two remain open today, with only one remaining as a nightclub).
CONCLUSION
The interior’s condition makes it obvious to the historic entertainment use of the building. The level of performers here was also significant. The Florentine Gardens booked its main talent for long runs as opposed to shorter turnovers as was done at most clubs (Cocoanut Grove, Hollywood Palladium, etc.). Long term engagements of such legendary music stars as Paul Whiteman, The Mills Brothers, The Ink Spots, and Sophie Tucker, were unique and only increase the importance to Hollywood and the music industry of the Florentine Gardens.
Due to the association with people of significance on a regular basis, as well as on a more limited one (Marilyn Monroe’s first marriage and Fats Waller’s last concert were held here) especially with the entertainment industry in Hollywood, California Register conditions for criteria i and ii are met.
Due to the facts that the Neg Dec: 1) ignores the Hollywood Redevelopment Plan; 2) ignores the actual need of the project so as to eliminate any negative impacts; 3) is biased in its historic assessment for findings that do not accurately describe the exterior and interior conditions; 5) the association with persons of significance is dismissed. Based on these conclusions, the Neg Dec is not adequate under CEQA and Hollywood Heritage therefore demands that a full EIR be prepared as is required under CEQA for a proposed project such as this.
Robert W.
Nudelman
Director of Preservation Issues
Hollywood Heritage